COMPLAINT FILED 9/30/98 PROPOSING A PENALTY $14,600. COMPLAINT ALLEGES: COUNT 1 RESPONDENT FAILED TO MAINTAIN A COMPLETE ANUAL DOCUMENT LOG TO REFLECT ALL PCB WASTE ACTIVITIES FOR THE 1995 CALENDAR YEAR. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.180(A) (2). COUNT II RESPONDENT FAILED TO MAINTAIN A COMPLETE ANNUAL DOCUMENT TO RELECT ALL PCB WASTE ACTIVITIES FOR THE 1994 CALENDAR YEAR. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.180(A) (2). COUNT III RESPONDENT FAILED TO MAINTAIN A COMPLETE ANNUAL DOCUMENT TO REFLECT ALL PCB WASTE ACTIVITIES FOR THE 1993 CALENDAR YEAR. IN VIOLATION OF TSCA SECTION 761.180(A) (2). COUNT IV RESPONDENT FAILED TO MAINTAIN RECORDS FOR EACH BATCH OF PCB-CONTAMINATED OIL THAT WAS DEPOSITED INTO THE 220-GALLON PCB CONTAINER AT THE NELSON COUNTY STORAGE FACILITY. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(C) (8). COUNT V RESPONDENT FAILED TO MAINTAIN RECORDS FOR EACH BATCH OF PCB CONTAMINATED OIL THAT WAS DEPOSITED INTO THE 220-GALLON PCB CONTAINER AT THE BULLITT COUNTY STORAGE FACILITY. IN VIOLATION OF TSCA 40 C.F.R. SECTION